The Commission's Forced Labour guidance, launched on 26 June, sets out guidance for competent authorities and economic operators on the application of Regulation (EU) 2024/3015, which prohibits products made with forced labour from being placed on, made available on, or exported from the European Union market.

The Regulation, adopted in November 2024 and entering into application on 14 December 2027, represents an important milestone in the fight against forced labour. It introduces binding obligations for all economic operators, regardless of their size, and applies to all products, irrespective of their origin, sector or type, where forced labour has been used at any stage of the supply chain, from extraction and harvesting to production, manufacturing, processing or the production of components.

For IndustriAll Europe, this legislation has the potential to become a powerful tool to protect workers and strengthen corporate accountability. However, its effectiveness will depend on robust implementation, adequate resources for enforcement authorities, and meaningful involvement of workers and trade unions.

Judith Kirton-Darling, General Secretary of industriAll Europe, said:

"Forced labour is one of the worst forms of exploitation. Behind every case are people whose rights, dignity and freedom have been taken away. It has no place in our supply chains or in the products sold on the European market.

The EU Forced Labour Regulation gives us an important new tool to tackle these abuses, but legislation alone will not end forced labour. What matters now is how it is implemented and enforced. Workers and their trade unions must be at the heart of that process. We are often the first to uncover abuses, support workers and bring evidence to light, and our role must be fully recognised throughout investigations.

The Commission's guidance is an important step forward. Now we need the political will, the resources and the commitment to make sure this Regulation delivers what workers need most: real protection, accountability for those responsible, and supply chains free from forced labour."

IndustriAll Europe particularly welcomes several aspects of the guidance published by the European Commission. It provides a clearer understanding of forced labour, centred around the key concepts of involuntariness and coercion, and confirms the broad scope of the Regulation, covering forced labour occurring at any stage of production, including extraction, harvesting, manufacturing and processing.

The guidance also recognises the challenges involved in documenting forced labour cases and provides flexibility regarding evidence requirements. This is particularly important given that forced labour often occurs in hidden parts of supply chains, where workers may face intimidation, retaliation or restrictions on their ability to speak freely.

IndustriAll Europe welcomes the recognition that:

• workers and petitioners must be protected throughout investigations, including through confidentiality safeguards;
• a wide range of evidence sources should be considered;
• non-cooperation by economic operators may itself constitute relevant evidence; and
• evidence from social audits should not automatically be considered reliable where workers are under threat, surveillance or management pressure.

The guidance also acknowledges the particular difficulties linked to identifying and investigating State-imposed forced labour, where workers may face additional barriers to reporting abuses and where traditional due diligence mechanisms may prove insufficient.

While welcoming the guidance, we stress that important gaps remain. The exclusion of services, such as construction, transport, logistics and maintenance, from the Regulation is a major shortcoming, particularly for sectors relying on subcontracting. The Commission should also strengthen the guidance by ensuring independent verification of company information, limiting reliance on social audits, providing more practical guidance on remediation and State-imposed forced labour, and equipping competent authorities with the resources needed for effective enforcement.

Manufacturing is among the sectors most exposed to forced labour risks due to complex global supply chains and subcontracting. From 14 December 2027, trade unions and other stakeholders will be able to submit evidence to the European Commission, potentially triggering investigations and the removal of products made with forced labour from the EU market. In this context, trade unions will play a crucial role, and IndustriAll Europe will continue working to ensure that this new legislation delivers what matters most: effective protection for workers and an end to forced labour in global supply chains.